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CENTRAL TEXAS SAV. & LOAN ASS'N v. U. S.

No. 83-1169.

731 F.2d 1181 (1984)

CENTRAL TEXAS SAVINGS & LOAN ASSOCIATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

May 11, 1984.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Jonathan S. Cohen, Terry L. Fredricks, Appellate Sect., Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellant.

Beard & Kultgen, Pat Beard, Waco, Tex., for plaintiff-appellee.

Before RUBIN, REAVLEY and GARWOOD, Circuit Judges.

REAVLEY, Circuit Judge:

The government appeals the decision of the district court holding that expenditures made in investigating and establishing new branches of a savings and loan association were deductible expenses under 26 U.S.C. § 162(a) (1976). We agree with the government's contention that such expenditures should have been capitalized.

I. Statement of the Case

Central Texas Savings & Loan Association (Central Texas), with its principal...

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